Fall Regulatory Summit

Internal Use Only

Reportable Incidents - Comments

Reporting obligations vary by state, and, in some states, materials provided as part of the license record may be accessible to the public under a Freedom of Information Act request. Some states allow the Licensee to request confidential treatment of certain matters. By requiring the filing as part of the license record in the NMLS, the Licensee would not have the benefit of this option.

One of the companies suggested a disclosure question to elicit this information. The respondent asserted “this would preserve the option to request confidential treatment where applicable and/or the ability to submit the notice without it being made a part of the licensing record. This is especially if the detailed information included in the notice provides information regarding vulnerabilities, internal control failures or other matters that could prove detrimental to Company, its vendors, or consumers if made available to individuals or entities seeking to obtain this information for nefarious purposes.”

Internal Use Only

Mortgage Business-Specific Requirements Policy Review as Part of the Application Process Agencies run the gamut from requiring a copy of certain policies to not inquiring about their existence. • 1. Certification Process • 2. Submission of the Policy Proposal: